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A visit from OSHA can be unwelcome and unsettling, but it need not be. By planning and preparing in advance, employers can minimize their discomfort over the pending inspection and obtain more control over the event.
The law firm of Pepper Hamilton LLP shares the following tips:
- Always have someone trained and designated to talk with and escort the inspector around the facility. Make it company policy that the designated person and/or the plant manager be informed prior to beginning the tour.
- Have the required OSHA documents available, isolated from proprietary or confidential information and in a form easily presented to the inspector.
- Anticipate issues and, if possible, prepare responses.
- Control the inspector’s route through the facility and how information is communicated to the inspector.
- Proactively ask about the inspector’s concerns during the inspection and, if possible, correct deficiencies immediately or, when appropriate, explain why an apparent deficiency is not worthy of a formal citation.
- Don’t feel pressured. If asked a question or requested to provide a document that you are unsure of or uncomfortable about, stop and take the time to consult a superior, an attorney, etc.
- Don’t volunteer or admit non-compliance. You should cooperate with the inspector and should seek and correct any safety or health issues. But it’s generally not prudent to volunteer information that is not requested. Also, because determining a violation may need legal and technical analysis, don’t admit to alleged violations during the inspection.
Source: Preparing, Planning and Cooperating Can Ease OSHA Inspections, Pepper Hamilton LLP, 100 Renaissance Center, Suite 3600, Detroit, MI 48243; telephone: 313-259-7110.
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